We have several doctors within our primary care group that also work as independent contractors with nursing homes to fill the role of medical director. By rule, the medical director has to visit with each patient of the nursing home whether he/she is a patient of that doctor or not. The doctor does not actually treat a person unless he/she is a patient of that doctor, but he does see the all of the patients' records and is therefore exposed to their PHI. My question is, do we need a BAA with those nursing homes since our doctors are seeing PHI of non-patients, and it is not for treatment purposes? These physicians, while working as independent contractors, have an agreement with the rest of the primary care group in regards to contracting out that ultimately means that the BAA would be with the group, not the individual physicians. Our question is whether there needs to be a BAA at all because of this scenario.
Regards, Mitch Kwiatkowski IS/IT Manager Preferred Primary Care Physicians --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
